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Issues: Whether interest earned on margin money and bank guarantee deposits can be treated as profits derived by the assessee from export of computer software for the purposes of Section 10A of the Income-tax Act, 1961.
Analysis: The question was stated to be covered by an earlier Division Bench decision of the same court, and the revenue did not dispute that position. In view of that binding position, the court answered the question without entering into the merits of the other substantial questions, which were not adjudicated.
Conclusion: The question was answered in favour of the assessee and against the revenue.
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